G.R. No. 246793 - HCL Technologies Philippines, Inc. vs. Guarin, Jr.

HCL Technologies Philippines, Inc. (HCL), a business process outsourcing company, hired Francisco A. Guarin, Jr. on November 11, 2013, as its senior technical support officer.
Guarin, Jr. was initially assigned to the Salesforce.com Inc. account where he was tasked to provide technical support to administrators and users.
On July 5, 2016, Salesforce informed HCL that it would no longer require HCL’s services effective October 15, 2016, thereby affecting Guarin, Jr.’s assignment.

Although two positions (support engineer for the App Engine and for the Computer Engine) were available in the Google account, Guarin, Jr. submitted his resume after the deadline.
Guarin, Jr. was subsequently directed not to return to work beginning October 1, 2016, and on October 15, 2016, HCL notified him, via a letter, that his position had become redundant with his last working day set as November 15, 2016.
Guarin, Jr. executed a release, waiver, and quitclaim acknowledging receipt of separation pay amounting to P182,340.65.

Declared Guarin, Jr. to have been illegally dismissed;
Ordered HCL to pay backwages from the time of dismissal until the finality of the decision;
Awarded moral and exemplary damages amounting to P100,000.00 and attorney’s fees of 10% of the total award;
Held that HCL satisfied only the first two requisites for a valid redundancy (notice and separation pay) but failed to show good faith in abolishing the redundant position and did not use fair and reasonable criteria in deciding redundancy.

Partially granted the appeals of both parties by modifying the award computation;
Upheld that HCL did not prove the abolition of Guarin, Jr.’s position or a valid redundancy scheme;
Declared the quitclaim invalid on the basis that Guarin, Jr.’s execution was not proven to be voluntary given the circumstances.

Affirmed the NLRC Decision with a modification imposing legal interest on monetary awards at 6% per annum;
Reiterated that HCL only complied with the notice and separation pay requirements, failing to establish the good faith and criteria requisites;
Held the quitclaim invalid, pointing to fraud or deceit in its execution.

Petition for Review on Certiorari filed by HCL before the Supreme Court, challenging the rulings of the lower tribunals.

Whether the CA erred in affirming the NLRC and the LA that Guarin, Jr. was illegally dismissed.

Whether HCL’s redundancy program satisfied all the legal requisites under Article 298 of Presidential Decree No. 442 (the Labor Code of the Philippines).
Whether the requirement of good faith and the establishment of fair and reasonable criteria in abolishing redundant positions were met by HCL.
The validity of the release, waiver, and quitclaim executed by Guarin, Jr., specifically if it was procured by fraud, deceit, or unconscionable terms.